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This University of Illinois Alumni Association Supplemental Privacy Policy — Personal Information Protection Law (“Supplemental Privacy Policy – PIPL”) supplements the University of Illinois Alumni Association Privacy Policy for certain persons in the People’s Republic of China (“PRC”). For the purposes of this Supplemental Privacy Policy – PIPL, “PRC” shall refer to the continental landmass under the direct control of the PRC, including the islands of Hainan Province and five major autonomous regions (e.g., Tibet, Inner Mongolia, Xinjiang, Ningxia and Guangxi), but excluding the Hong Kong Special Autonomous Region (SAR), Macao SAR and Taiwan.

1. Commitment to protecting privacy and transparency

The University of Illinois Alumni Association (“UIAA”, “we”, “us” or “our”), as the organization that oversees services that engage and benefit alumni of the University of Illinois Urbana-Champaign (the “University”), is committed to respecting and protecting the privacy rights of persons in the PRC consistent with the PRC’s Personal Information Protection Law (“PIPL”).

This Supplemental Privacy Policy – PIPL describes UIAA’s commitment to the privacy of persons in the PRC.

2. Does this Supplemental Privacy Policy — PIPL apply to me?

This Supplemental Privacy Policy — PIPL applies to you if:

  • You are a “Person” or “Data Subject” — meaning a natural person, not a corporation, partnership, or other legal entity;

AND

  • UIAA handles your Personal Information inside the borders of the PRC.

OR

  • You are physically located in the PRC, and
  • UIAA handles your Personal Information outside the borders of the PRC in order to 1) provide you goods or services, 2) analyze or assess your activities, or 3) comply with other circumstances as provided by laws or administrative regulations.

“Personal Information” means any information relating to an identified or identifiable natural person, not including information after anonymization handling. For the purposes of PIPL, “anonymization” refers to the process of Personal Information undergoing handling to make it impossible to distinguish specific natural persons and impossible to restore.

If you are located outside the PRC and you provide your Personal Information to UIAA outside the PRC, this Supplemental Privacy Policy – PIPL does not apply to that information.

3. What Personal Information does UIAA process?

General categories

UIAA processes the following general categories of Personal Information: names; addresses; telephone numbers; email addresses; identification numbers including but not limited to social security numbers, driver’s license numbers, University identification numbers, and personal identification numbers (PINs); usernames; passwords; demographic information; education history; background check information; personal references; financial information including but not limited to credit and debit card numbers and tax information; transaction history; business information; passport and visa information; work history; social media URLs; donation history; insurance information; military service; IP addresses; location information; device information; metadata; any requests for accommodations or leave; and other information to support the purposes set forth in Table 1, below.

UIAA requires Personal Information only when necessary. Table 1 identifies the purposes for which UIAA processes Personal Information and the legal basis for each purpose.

Sensitive Personal Information

In order to fulfill certain of the purposes identified in Table 1, UIAA may need to request Sensitive Personal Information. Sensitive Personal Information is a special type of Personal Information that, if leaked or used illegally, could cause harm to a person’s dignity or grave harm to personal or property security. Examples of Sensitive Personal Information identified in PIPL include but are not limited to:

  • Biometric characteristics
  • Religious beliefs
  • Specially-designated status
  • Medical health-related information
  • Financial accounts
  • Individual location tracking
  • Personal Information concerning minors under the age of 14

UIAA will only process Sensitive Personal Information when necessary for a specific purpose and will take strict protective measures to ensure the security of the information obtained. Before UIAA processes your Sensitive Personal Information, UIAA will ask for your separate consent.

Purposes for which UIAA processes Personal Information
Table 1


Purpose Legal Basis
To process Personal Information collected from individuals who contact UIAA: (i) to deal with their inquiries or requests; or (ii) to provide them with news by mail or email about UIAA or any projects, campaigns, programs or events that UIAA may be involved in or how they can support UIAA Consent
To stay connected with University alumni and to provide information about the UIAA and the University Consent
To contact individuals regarding UIAA and University events and programs, as well as to offer you products and services due to your affiliation with the University Consent
To host and allow individuals to attend and participate in UIAA events and programs Consent
To allow individuals to visit UIAA facilities Consent
To facilitate networking and mentorship opportunities involving alumni, faculty or staff, non-alumni mentors, and current University students Consent
To facilitate the use of volunteers and to evaluate and manage individuals who volunteer to assist UIAA in any capacity, and to perform related activities required to foster and maintain these relationships Consent
To conduct direct fundraising marketing by mail, telephone, or electronic message (e.g., email or SMS) Consent
To conduct transactions and business with individuals, such as offering UIAA memberships, processing membership dues and other payments made by cash, check, or credit card to UIAA, and processing payments made by UIAA to you Necessary for the conclusion or performance of a contract where you are an interested party
To facilitate application for and sponsoring of visas to work at UIAA, including all functions necessary to comply with applicable immigration laws

Necessary for the conclusion or performance of a contract where you are an interested party or conduct human resources management according to lawfully formulated labor rules and structures and lawfully concluded collective contracts

To respond to a UIAA member’s request regarding Alumni Association records pertaining to that UIAA member Consent
To respond to an individual’s request for records relating to that individual’s time at UIAA, such as tax documents, employment documents, etc. Necessary for the conclusion or performance of a contract where you are an interested party or conduct human resources management according to lawfully formulated labor rules and structures and lawfully concluded collective contracts
To engage the services of an independent contractor and all uses incident to that engagement Necessary for the conclusion or performance of a contract where you are an interested party or conduct human resources management according to lawfully formulated labor rules and structures and lawfully concluded collective contracts
To employ persons to work for UIAA and all uses incident to that engagement including but not limited to evaluation and management of employees and administration of employee benefits

Necessary for the conclusion or performance of a contract where you are an interested party or conduct human resources management according to lawfully formulated labor rules and structures and lawfully concluded collective contracts

To facilitate review and evaluation of UIAA programs by the UIAA, government entities, third-party ranking organizations, and other appropriate bodies Necessary to fulfill statutory duties or statutory obligations or Consent
To promote safety, integrity, and security of UIAA’s information technology systems Necessary to fulfill statutory duties or statutory obligations
To protect the UIAA community, including you, and to keep its members safe wherever they are located Necessary to fulfill statutory duties or statutory obligations
To report salary data to social security or tax authorities and otherwise comply with applicable laws Necessary to fulfill statutory duties or statutory obligations
To respond to subpoenas, court orders, agency requests, and other legal requests for records relating to an individual’s association with UIAA Necessary to fulfill statutory duties or statutory obligations

 
4. How does UIAA receive your Personal Information?
 
From you
 
UIAA may receive your Personal Information from you when you:
  • Use the UIAA website to sign up to receive information from UIAA, enter your Personal Information on a UIAA form to register for an event, and/or ask about volunteer opportunities or other ways you can support UIAA;
  • Inquire about making a donation to UIAA and/or the University or if you agree to make a donation to UIAA; and,
  • Provide your Personal Information to UIAA for other purposes.

From others

UIAA may receive your Personal Information from others:

  • When the University, the University of Illinois Foundation (“UIF”), or the University of Illinois Foundation UK Limited (“UIUK Foundation”) shares your Personal Information with UIAA;
  • When UIAA contracted vendors to whom you directly provided information, such as through the Alumni Directory and IlliniLink, share your personal information with UIAA; and,
  • Through web tools, cookies, and related technologies used on UIAA websites.

    5. Who receives/processes your Personal Information?

UIAA

Your Personal Information may be processed by UIAA directors, employees, and volunteers as may be necessary to carry out the purposes for processing the information and the activities of UIAA.

Related Organizations

UIAA may share your Personal Information with UIF and the UIUK Foundation, which may use the information to assist in raising funds to support the University and its programs. In addition, your Personal Information may be shared with the University, which shares our commitment to treating Personal Information responsibly.

Third parties

UIAA may share your Personal Information with third parties, such as: service providers to facilitate the full range of UIAA functions (e.g., cloud storage, software, process credit card transactions); and vendor partners to connect you with other alumni and current students (e.g., PeopleGrove processes your Personal Information for IlliniLink) and other alumni and friends of the University through the Alumni Directory (e.g., OmniMagnet, LLC, processes your Personal Information for the Alumni Directory); and to offer you products and services due to your affiliation with the University (e.g., alumni travel and financial product opportunities).

We take reasonable steps so that any Personal Information we collect is only used by those third parties for specific, lawful purposes in line with this Supplemental Privacy Policy – PIPL.

Please note that UIAA may provide anonymized data developed from Personal Information to third parties, such as our peers, industry groups, and government entities, and that such anonymized data is outside the scope of this Supplemental Privacy Policy – PIPL.

6. Data Retention
 
UIAA keeps records in accordance with applicable laws and for purposes of business continuity and in support of anticipated constituent requests. All retained information is stored in a manner designed to ensure its accessibility, integrity, confidentiality, authenticity and legibility.
 
7. What are your rights as a Data Subject?
 
As a Data Subject pursuant to the PIPL, you have certain rights. This Supplemental Privacy Policy – PIPL summarizes these rights and how you can exercise these rights. More detail about each right, including exceptions and limitations, can be found in Articles 15 and 44 through 50 of the PIPL.

Please note: Nothing in this Supplemental Privacy Policy – PIPL is intended by UIAA to waive any defenses or immunities afforded by any or all U.S. federal laws, Illinois state laws, PRC law, or international law.

Right to know and make decisions

You have the right to know and make decisions about the processing of your Personal Information, and the right to limit or refuse the handling of your Personal Information by others, unless otherwise provided for by law.

If the purpose or method of processing your Personal Information or the type of Personal Information or who has access to your Personal Information changes, you will be notified and asked to re-consent to the change(s).

Right to consult or copy

You have the right to consult or copy your Personal Information, except when it is necessary for UIAA to maintain confidentiality or when otherwise provided for by applicable law. UIAA will respond to your requests to consult or copy your Personal Information in a timely manner.

Right to request transfer

You may request that UIAA transfer your Personal Information to another personal information handler. If UIAA is permitted to make the transfer under applicable law, UIAA will facilitate the transfer.

Right to have inaccurate Personal Information corrected or supplemented

You have the right to request that UIAA correct any inaccurate Personal Information that it maintains about you. You also have the right to request that UIAA complete any incomplete Personal Information that it maintains about you, which could be accomplished by incorporating a supplementary statement that you submit. If UIAA concurs that the Personal Information is incorrect or incomplete, UIAA will correct or complete it in a timely manner.

Right to request deletion

You have the right to request the deletion of Personal Information that UIAA maintains about you in certain circumstances. These circumstances are identified in Article 47 of the PIPL and include that the Personal Information is no longer necessary in relation to the purpose(s) for which it was collected.

Subject to applicable U.S. federal and state law and UIAA policies, including but not limited to the UIAA Privacy Policy and any required record retention periods, and provided that there are no overriding legitimate grounds for UIAA to retain the Personal Information, UIAA will comply with deletion requests meeting the requirements of applicable law. For the avoidance of doubt, where deletion has been requested but is technically hard to realize, UIAA shall cease processing the Personal Information other than for storage and taking necessary security protective measures.

Right to have the rules of processing explained

You have the right to request that UIAA explain to you the Personal Information handling rules.

Right to withdraw consent

If the basis for processing your Personal Information is consent, you may revoke your consent at any time. Upon receipt of your notice withdrawing consent, and if there are no other legal grounds for the processing, UIAA will stop processing the Personal Information unless the processing is necessary for the establishment, exercise, or defense of legal claims or is otherwise permitted by applicable law. Revoking consent does not affect the lawfulness of processing that occurred before the revocation.

Your refusal to provide consent or your subsequent withdrawal of consent will not impact your ability to access UIAA goods and/or services, to the extent such goods and/or services are applicable to you; provided however, it may prevent provision of UIAA goods and services that are dependent on such a consent.

Right to file a lawsuit

If UIAA rejects your request to exercise your rights, you may file a lawsuit in a court of competent jurisdiction according to the law.

8. How to exercise your rights

In order to exercise any of your rights with UIAA, except the right to file a lawsuit in a court of competent jurisdiction, you should submit your request to our UIAA data privacy team:

Email: alumnigdprrequest@uillinois.edu

Telephone: +1 217-244-0640

Address:
University of Illinois Alumni Association
Alice Campbell Alumni Center
601 S. Lincoln Avenue
Urbana, IL 61801
Attn: Privacy Compliance

At that time, you will be asked to: 1) identify yourself; 2) provide information to support that the PIPL applies to you (see Section 2, above); 3) identify the specific information or data that you are concerned about; and 4) state what right(s) you wish to exercise.

To expedite processing your request, please identify the data collection location (e.g., the website where your Personal Information was collected), if known.

In the event of a death, the next of kin of a deceased natural person may exercise the rights of an individual provided in this Supplement Privacy Notice – PIPL, such as the right of consulting, copying, correcting, and/or deleting Personal Information of the deceased as detailed above, except where the deceased natural person has arranged otherwise before his/her death.

If your request to exercise your rights under PIPL is rejected, UIAA will explain the reason.

9. How does UIAA respond to requests for Personal Information?

In addition to the rights provided by the PIPL, you may also have rights with respect to your Personal Information pursuant to U.S. federal law, state law, or UIAA policy. When you submit a request to UIAA to exercise your rights, UIAA will respond in accordance with existing UIAA policies and procedures that implement the relevant privacy law(s).

10. Existence of automated individual decision-making

UIAA, in conjunction with the University and UIF, uses automated decision-making, including profiling, to help identify prospective supporters of the University and its activities. The logic takes an all-factor approach to assessing a possible donor’s propensity to support the University and may result in a prospective donor being contacted to explore support opportunities. For the purposes of the PIPL, “automated decision-making” refers to the activity of using computer programs to automatically analyze or assess personal behaviors, habits, interests, or hobbies, or financial, health, credit, or other status, and then making decisions based on the analysis of such information.

You will not be subject to a decision having a major influence on your rights and interests based solely on automated processing, including profiling, unless you explicitly consent.

11. Transfer of Personal Information outside the PRC

UIAA is based in the U.S. and is subject to U.S. and Illinois law. Personal Information that you provide to UIAA will generally be hosted on U.S. servers. To the extent that UIAA needs to transfer your information either (a) from the PRC to the U.S. or another country or (b) from the U.S. to another country other than the PRC, UIAA will do so consistent with applicable law governing such transfers. To support such transfers, UIAA will generally seek to enter into a contract containing certain standard terms to clearly establish the rights and responsibilities of the parties to the transfer.

In addition, to the extent the following information is not included in this Supplemental Privacy Policy – PIPL, the UIAA will notify you of the of the name and contact information of the overseas recipient, the purpose of the transfer and method of processing, the type of Personal Information involved, and how you can exercise your rights. UIAA will also obtain your separate consent to the transfer unless such separate consent is not required by applicable law.

12. How do I contact the Personal Information handler?

UIAA is the personal information handler. If you have any questions about anything contained in this Supplemental Privacy Policy – PIPL, please contact our UIAA data privacy team:

Emailalumnigdprrequest@uillinois.edu

Telephone: +1 217-244-0640

Address:
University of Illinois Alumni Association
Alice Campbell Alumni Center
601 S. Lincoln Avenue
Urbana, IL 61801
Attn: Privacy Compliance

13. Updates to Supplemental Privacy Policy – PIPL

UIAA may update this Supplemental Privacy Policy – PIPL from time to time. Any changes will become effective upon posting of the revised Supplemental Privacy Policy – PIPL.


Effective: 11/01/2021
Last revised: 7/01/2022